IN RE COMMITMENT JAMES WILLIAMS. JAMES WILLIAMS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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James Williams appealed a civil commitment order entered under Florida's Jimmy Ryce Act, raising six constitutional and evidentiary issues. The court affirmed the commitment order, rejecting challenges based on substantive due process, scientific evidence admissibility under the Frye test, and the use of hearsay evidence from police reports in expert testimony.
The court affirmed the commitment order on all grounds. The substantive due process challenge was rejected based on prior Florida Supreme Court precedent. Any error in admitting risk assessment results was harmless error. The use of hearsay from police reports was permissible because the reports documented offenses for which Williams had been convicted, the evidence had been subjected to trial scrutiny, and the commitment was based on more than just hearsay evidence.
[1] The Jimmy Ryce Act does not violate the substantive due process requirements of the Florida and federal constitutions.
[2] An error in admitting the results of risk assessment instruments is subject to a harmless error analysis.
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Join FLexlaw to unlock all legal intelligence“such an error, if it occurred, is subject to a harmless error analysis”
Establishes that any error in admitting risk assessment results does not require reversal if harmless
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Join FLexlaw to unlock all legal intelligenceJames Williams was subject to a commitment proceeding under the Jimmy Ryce Act. Expert witnesses relied on risk assessment instruments to evaluate Wil…
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PER CURIAM.
James Williams appeals the order of commitment entered under the Jimmy Ryce Act (the Act).1 Of the six issues raised, we affirm three of these with discussion and affirm the other three without comment.
The first issue we address is Williams’ claim that the Act violates the substantive due process requirements of the Florida and federal constitutions. The supreme court has rejected this argument in Westerheide v. State, 831 So. 2d 93 (Fla.2002).
Williams also argues that the results of the risk assessment instruments used by the expert witnesses were improperly introduced into evidence as they did not properly meet the Frye
test for admissibility as scientific evidence. As this court determined in Green v. State, 826 So. 2d 351 (Fla. 2d DCA 2002), such an error, if it occurred, is subject to a harmless error analysis. After reviewing the record of the testimony and evidence presented to the trial court, we are satisfied that even if the admission of these assessment results was error, it was harmless. See State v. DiGuilio, 491 So. 2d 1129, 1135 (Fla.1986). Accordingly, we need not address the applicability of Frye or whether the instruments met the requirements of that test.
Finally, Williams suggests that the use of hearsay statements that certain expert witnesses took from police reports to support their opinions was error. In explaining how they reached their opinions, certain experts called by the State referred to facts cited in police reports regarding the details of prior sexual offenses for which Williams previously had been convicted. Williams argues that Jenkins v. State, 803 So. 2d 783 (Fla. 5th DCA 2002), prohibits such use of those statements because, as was the case in Jenkins, Williams was denied the opportunity to cross-examine the author of those statements.
However, the Jenkins decision is distinguishable from the facts in this case. In Jenkins, the reports included not only hearsay, but double hearsay. Furthermore, the reports from which the testimony in Jenkins came involved conduct for which no criminal charges were brought nor a conviction obtained. Finally, the Fifth District concluded that Jenkins’ commitment was based almost solely on hearsay evidence. By contrast, the evidence relied upon by the experts and testified to in court here came from reports on offenses for which Williams was previously convicted so that the essence of those statements had been either admitted by Williams or subjected to the scrutiny of a trial. Furthermore, Williams’ commitment was based on more than just this hearsay evidence. Accordingly, we find Jenkins distinguishable and affirm the trial court’s finding as to this issue as well.
Affirmed.
SALCINES and DAVIS, JJ., and GREEN, OLIVER L., SENIOR JUDGE, Concur. . Section 394.917(2), Florida Statutes (2000).
. Frye v. United States, 293 F. 1013 (D.C.Cir.1923).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
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In re Commitment: John R. Cartwright. John R. Cartwright v. State, 870 So. 2d 152 (Fla. 2d DCA 2004)…ide there was no majority opinion. Westerheide has nonetheless been cited by this court and other district courts as deciding the constitutional challenges involved in the case. See Lee v. State, 854 So. 2d 709 (Fla. 2d DCA 2003); Williams v. State, 841 So. 2d 531 (Fla. 2d DCA 2003); Hale v. State, 834 So. 2d 254 (Fla. 2d DCA 2002); McQueen v. State, 848 So. 2d 1220 (Fla. 1st DCA 2003); Jackson v. State, 833 So. 2d 243 (Fla. 4th DCA 2002). We also note that in State v. Goode, 830 So. 2d 817, 819 n. 1 (Fla.200…
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Masters v. State, 958 So. 2d 973 (Fla. 5th DCA 2007)…orts. Second, Masters’ civil commitment was not based solely on hearsay. There was ample non-hearsay evidence demonstrating that Masters had a problem and was likely to reoffend. Thus, Jenkins does not control. See also In re Commitment of Williams, 841 So. 2d 531 (Fla. 2d DCA 2003) (distinguishing Jenkins on similar grounds). Constitutionality of Section 394.9155(5), Florida Statutes (2006) Finally, Masters argues that section 394.9155(5), Florida Statutes (2006) is unconstitutional because it purports to…
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Ortega-Mantilla v. State, 898 So. 2d 1164 (Fla. 3d DCA 2005)…d on the record before us. See State v. DiGuilio, 491 So. 2d 1129, 1139 (Fla.1986) (holding that the harmless error test requires a showing that “there is a reasonable possibility that the error affected the verdict.”). See, e.g., Williams v. State, 841 So. 2d 531 (Fla. 2d DCA 2003) (applying DiGuilio to civil commitment proceeding); Collier v. State, 857 So. 2d 943, 946 (Fla. 4th DCA 2003) (same). Therefore, this argument presents no basis for reversal of the order. HI The appellant next asserts that the t…1 / 2
Previewing 3 of 7 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- State v. DiGUILIO, 491 So. 2d 1129 (Fla. 1986)
- Westerheide v. State, 831 So. 2d 93 (Fla. 2002)
- Jenkins v. State, 803 So. 2d 783 (Fla. 5th DCA 2001)
- In re Commitment of Joseph Green v. State, 826 So. 2d 351 (Fla. 2d DCA 2002)